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Andy Acuna

Gulf Coast Helicopters

4810 Comal St.

Pearland, TX 77588

281-636-2041

3 AUG 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Summary Processing: Exemption Request for Gulf Coast Helicopters, Inc. Under Section 

333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. §§

61.113(a) and (b); 91.7 (a); 91.119(c); 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 

91.407(a)(1); 91.409(a)(2); 91.417(a) and (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Gulf Coast Helicopters, Inc. (“Gulf Coast Helicopters”) operator of 

Small Unmanned Aircraft Systems (“UAS”) equipped to conduct commercial flights including but 

not limited to the following (hereinafter “the Purpose”):

1. Oil and gas inspection of equipment and facilities including pipelines 

2. Television productions, music video productions, advertising and news gathering

3. Marketing of residential and commercial real estate

4. Aerial Photography and Videography 

5. Construction Companies Aerials to include Aerial Progressives

6. Inspection surveys i.e. agricultural land for farmers, roofing, oil & gas companies, 

shoreline protection for ecological concerns, land survey, forestry service, Powerline & 

Energy Stations, road & bridge inspections, Railway Inspection, Mining industry survey 

and inspection. 

7. Assist first responders/ or government agency in emergency matters, over land, 

water-ways, and oceans, disaster relief, medical supplies delivery and missing persons

8. State side virtual tours, special events

9. Public service, Aerial Data Collection

10. Training
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Gulf Coast helicopters hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA 

in an exemption granted under either Section 333.

As with the approval of the Similar Exemptions, approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in 

the national airspace system.” Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

Gulf Coast Helicopters Aerospace, Inc.

Attn: Andy Acuna

4810 Comal St.

Pearland, TX 77588

281-636-2041
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Regulations from which the exemption is requested: 

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

14 C.F.R. § 91.7 (a): Civil Aircraft Airworthiness

14 C.F.R. § 91.109: Flight Instruction 

14 C.F.R. § 91.119: Minimum Safe Altitude

14 C.F.R. § 91.121: Altimeter Setting

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

14 C.F.R. § 91.203(a) & (b); Carrying Civil Aircraft Certification and Regulation

14 C.F.R. § 91.405(a): Maintenance Inspection

14 C.F.R. § 407(a)(1): Maintenance Inspection

14 C.F.R. § 409(a)(2): Maintenance Inspection

14 C.F.R. § 417(a) and (b): Maintenance Inspection

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333(a). Lastly, if the Secretary determines that such vehicles “may operate 

safely in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added)1. 

The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform 

Act, expressly grants the FAA the authority to issue exemptions. This statutory authority by its 

terms includes exempting civil aircraft, as the term is defined under § 40101 of the Act, that 

includes UAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of the Transportation 

Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f). See also 

49 U.S.C. §§ 44711(a), 44704; 14 C.F.R. § 91.203(a)(1). 

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the 

UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements 

for approval.
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Gulf Coast Helicopters is Pipeline Inspection & Patrol Company that has more than 40 

years of safe flying history and will use the UAS to enhance our abilities for our customers as 

well as enhancing the safety of drone operations in the United States. Gulf Coast Helicopters

UAS’s are rotorcraft and weighting 55 or fewer lbs. including payload. They operate, under 

normal conditions at a speed of no more than 50 knots and have the capability to hover, and 

move in the vertical and horizontal plane simultaneously. They will operate at altitudes of no 

more than 400 feet, as further explained, and only in line of sight. They will operate only within 

the sterile areas as described in the Gulf Coast Helicopters Flight Operations Manual. Gulf 

Coast Helicopters will also operate a UAS’s that are fixed winged weighting 55 lbs or less,

including payload. They operate, under normal conditions at a speed of no more than 100 knots. 

They will operate at altitudes of no more than 400 feet, as further explained, and only in line of 

sight. They will operate only within the sterile areas as described in the Gulf Coast Helicopters 

Flight Operations Manual.

In support of this application, Gulf Coast Helicopters is submitting, with a request for 

confidentiality as shown, the following manuals (hereinafter “the Manuals”)2: 

• Gulf Coast Helicopters, Inc., Air Carrier Certificate

• Gulf Coast Helicopters, Inc., UAS Flight Operations Manual (“FOM”), Exhibit 2 (Confidential) 

• Gulf Coast Helicopters UAS Quadcopter Aircraft Flight Manual, (Exhibit 3) (Confidential) 

• Gulf Coast Helicopters UAS Quadcopter Advanced Flight Manual, (Exhibit 3) (Confidential) 

• Gulf Coast Helicopters UAS Checklists, (Exhibit 4) (Confidential)

Operations in compliance with these manuals will insure that the UAS will “not create a 

hazard to users of the national airspace system or the public”3 and that the aircraft will operate 

in compliance with the conditions set forth in this application. 

Given the small size of the UAS involved and the restricted environment within which 

they will operate, Gulf Coast Helicopters falls within that zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately. Also due to the size of the UASs, the restricted 

areas in which the relevant UAS will operate and the fact that aircraft will be flown by pilots 

holding at least a FAA private pilot license, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including enhanced 

safety, reduction in environmental impacts, including reduced emissions associated with 

allowing battery powered UASs for these functions instead of turbine or gas power 

aircraft/rotorcraft and operations with pilots having at least a private pilot license, the grant of the 

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay. 

2 Applicant submits the Manuals, marked “CONFIDENTIAL”, as they contains propriety business 

information that is not released to the public and is protected under the Freedom of Information Act, 

5 U.S.C. § 553, etc. 

3 Reform Act Section 333(b). 

4 These conditions are reproduced from Similar Exemptions (11062 through 11067, 11080, 11150, 11158 

11160, 11161 and 11172).
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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or even higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to the 

already safe Pipeline Inspection & Patrol, Photography, Filming, Inspecting operations 

conducted with our conventional aircraft.4

Gulf Coast Helicopters notes that a requested Certificate of Authorization (COA) not be 

required for flight at or below 400 feet AGL, in Class G airspace and outside of 5 nautical miles 

from the geographic center of airport where a letter of agreement has not been entered with the 

airport management. 

These limitations and conditions to which Gulf Coast Helicopters agrees to be bound 

when conducting commercial operations under an FAA issued exemption include: 

1. The UAS must weigh less than 55 pounds, including energy source(s) and equipment. 

Operations will be limited to the aircraft described in the proprietary Manuals: 

2. The UAS may not be flown at a speed exceeding a ground speed of 50 knots (Quad 

Copter, and 100 knots (Fixed Wing). 

3. Flights must be operated at an altitude of no more than 400 feet above ground level 

(AGL) as indicated by the procedures specified in the Operators Manuals. All altitudes 

reported to ATC must be in feet AGL. 

4. The UAS must be operated within visual line of sight (VLOS) of the PIC/VO(s) at all 

times. This requires the PIC/VO(s) to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued medical 

certificate. 

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times. 

6. The operator will be bound by and follow the Manuals as accepted by the FAA. Any 

additional requirements identified in the final conditions for this Exemption will be added 

to the Manuals. The Manuals will be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions and limitations in the final 

exemption and the procedures outlined in the Manuals, the conditions and limitations of 

the Exemption will take precedence and will be followed. Otherwise, the operator will 

follow the procedures as outlined in its Manuals. The operator will update or revise its 

Manual. It will be the operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. 

The operator will also present updated and revised documents in its petitions for 

extension or amendment. If the operator determines that any update or revision would 

affect the basis for which the FAA granted this exemption, then the operator will petition 

for amendment to their exemption. The operator will contact the FAA’s UAS Integration 

Office (AFS-80) with questions arising regarding updates or revisions to the Manual. 
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7. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft will not operate until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, 

will be included in the preflight inspection. All maintenance and alterations will be 

properly documented in the aircraft records. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight in accordance with the Manual. The PIC who conducts the functional 

test flight must make an entry in the UAS aircraft records of the flight. The requirements 

and procedures for a functional test flight and aircraft record entry must be added to the 

Manuals. 

9. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance 

requirements will be established and identified in the Manuals. At a minimum, the 

following must be included in the Manual: 

a. Actuators / Servos 

b. Transmission (single rotor) 

c. Powerplant (motors) 

d. Propellers 

e. Electronic speed controller 

f. Batteries 

g. Mechanical dynamic components (single rotor) 

h. Remote command and control 

i. Ground control station (if used) 

j. Any other components as determined by the operator 

10. The PIC will possess at least a private pilot certificate.

11. Prior to operations conducted for the Purpose, the PIC will have accumulated and 

logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type 

(single blade or multirotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations will be used to satisfy this requirement. Training, 

proficiency, and experience-building flights may also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations 

will be considered non-participants, and the PIC will operate the UAS with appropriate 

distance from non-participants in accordance with 14 C.F.R. § 91.119. 

12. Prior to operations conducted for the purpose of Pipeline Station/Valve Inspections (or 

similar operations), the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), a minimum of five hours as UAS pilot operating the make and 

model of UAS to be utilized for operations under the exemption and three take-offs and 

three landings in the preceding 90 days. Training, proficiency, experience-building, and 

take-off and landing currency flights can be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, 
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experience-building, and take-off and landing currency flights all persons not essential 

for flight operations are considered nonparticipants, and the PIC must operate the UAS

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

13. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must 

have successfully completed a qualification process, as outlined in the operator’s 

manual. As this is a requirement stipulated by the operator, the test must be developed 

and implemented by a qualified person designated at the sole discretion of the operator. 

A record of completion of this qualification process must be documented and made 

available to the Administrator upon request. 

14. Prior to operations conducted for the Purpose, a flight demonstration, administered by 

an operator-approved and -qualified pilot will be successfully completed and 

documented. This documentation will be available for review upon request by the 

Administrator. Because the knowledge and airmanship test qualifications will be 

developed by the operator, and there are no established practical test standards that 

support a jurisdictional FAA Flight Standards District Office (FSDO) evaluation and 

approval of company designated examiners, the Operator will conduct these tests in 

accordance with the Manual. 

The UAS will not be operated directly over any person, except authorized and 

consenting personnel necessary for the Purpose, below an altitude that is hazardous to 

persons or property on the surface in the event of a UAS failure or emergency. 

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a) Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAS and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately and/or; 

b) The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and; 

c) Operations nearer to the PIC, VO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

operation to be conducted. 

See, Exemptions 11170, 11172 and 1117 for proposed language. 
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16. Prior to any flight, Operator will only be required to obtain an Air Traffic Organization 

(ATO) issued Certificate of Waiver or Authorization (COA) for flights that are conducted 

at heights greater than 400 AGL; in other than Class G airspace; and closer than 5 miles 

from the geographic center of a non-towered airport, without a letter of agreement with 

the airport manager. If requested, Operator will provide telephonic advanced notice to an 

ATO or file a NOTAM for any flight not requiring a COA. 

17. If the UAS loses communications or loses its Global Positioning System (GPS) signal, 

the UAS will be programmed to return to a pre-determined location within the security 

perimeter and land or be recovered in accordance with the Manual. 

18. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the Manual. 

19. Each UAS sortie will be completed within 45 minutes flight time or with 25% battery 

power remaining, whichever occurs first. 

20. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) 

markings in accordance with 14 C.F.R. part 45, subpart C. Markings will be as large as 

practicable. 

21. The operator will develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures will be 

added to the Manual. 

22. Each UAS operated under this exemption will comply with all manufacturer Safety 

Bulletins. 

23. The operator will develop UAS technician qualification criteria. These criteria will be 

added to the Manual. 

24. The preflight inspection section in the Manual will be amended to include the following 

requirement: The preflight inspection will account for all discrepancies, i.e. inoperable 

components, items, or equipment, not covered in the relevant preflight inspection 

sections of the Manual. 

25. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS will comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

26. The documents required under 14 C.F.R. 91.9 and 91.203 will be available to the PIC at 

the ground control station of the UAS any time the aircraft is operating. These 

documents will be made available to the Administrator or any law enforcement official 

upon request. 

27. The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.). 
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28. UAS operations will not be conducted during night, as defined in 14 C.F.R. 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) will not be undertaken.

29. The UAS will not be operated by the PIC from any moving device or vehicle. 

30. The UAS will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

31. The UAS will not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS will not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a letter 

of agreement with that airport’s management is obtained, and the operation is conducted 

in accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management will be made available to the Administrator upon 

request. 

32. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 

hours. Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight 

operations will not be conducted until the incident, accident, or transgression is reviewed 

by AFS-80 and authorization to resume operations is provided. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 C.F.R. including, but not limited to, parts 

45, 47, 61, and 91. 

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to have 

a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike 

a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with 

no living thing on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance as set forth in the Manual. The level of safety provided by 

the requirements included in the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with the 

operation of the UAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the UAS as 

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 

C.F.R. § 61.113(a) and (b). 

The FAA has granted exemptions for private pilots to conduct similar operations in 

Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080. 
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14 C.F.R. § 91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained herein for the use of safety check 

lists prior to each flight, an equivalent level of safety will be provided. 

14 C.F.R. § 91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

UAS and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a radio transmitter that communicates 

with the aircraft via a receiver in the UAS. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos. 5778K & 9862A. 

The equivalent level of safety provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. § 91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a UAS that is a helicopter and a UAS Fixed wing and the 

exemption requests authority to operate at altitudes up to 400 AGL an exemption may be 

needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the location where it is operated. No flight will be taken without the permission of the 

property owner, facility owner and local officials. Because of the advance notice to the property 

owner and participants all affected individuals will be aware of the planned flight operations as 

set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the lowaltitude operations of the UAS will ensure separation between these small-UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 

The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 

11063, 11064, 11065, 11066, 11067 and 11080. 
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14 C.F.R. § 91.121: Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the UAS in at least one operating mode will not 

have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual and 

Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 

The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 

11063, 11064, 11065, 11066, 11067 and 11080. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. 

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes.” 

The battery powering the UAS provides approximately 40 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, UAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for 

flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 C.F.R. § 91.151(a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area 

where only people and property owners or official representatives who have signed waivers will 

be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. 

Gulf Coast Helicopters believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction 

would be more than adequate to return the UAS to its planned landing zone from anywhere in 

its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, 10808 and Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080. 
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14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and typically less than 20 lbs. and is 

operated without an onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying the UAS 

will have immediate access to them, to the extent they are applicable to the UAS. 

The FAA has issued numerous exemptions to this regulation. A representative sample of 

other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700. 

14 C.F.R. §§ 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, except 

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 

43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be accomplished by 

the operator pursuant to the flight manual and operating handbook as referenced in the Flight 

Operations and Procedures Manual (FOPM) attached as confidential Exhibit 2. (See) An 

equivalent level of safety will be achieved because these small UASs are very limited in size 

and will carry a small payload and operate only in areas for limited periods of time. If mechanical 

issues arise the UAS can land immediately and will be operating from no higher than 400 feet 

AGL. As provided in the FOPM, the operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. 

The FAA has granted exemptions for similar operations in Exemptions 11062, 11063, 

11064, 11065, 11066, 11067 and 11080.
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